Bees And Neonicotinoids - Please Write to EU Commissioner Borg

On the 29th April 2013, EU member
states will vote once more on whether to restrict use of just 3 of the
neonicotinoids. It is a small but important step. Some countries
voted against the restrictions last time, and it is expected that some
will do so again. Here is a letter to encourage EU Commissioner Borg to act
to uphold EU Law, and to continue to apply pressure on EU member states.

Firstly
I would like to thank you for your efforts to date with regard to the securing
of restrictions to the use of 3 neonicotinoids, to help protect bees and other
pollinators.

As the
next vote is shortly upon us (on 29th April) I write to impress upon you the following:

1. It
is the responsibility of the Commission to ensure member states uphold EU law. EU
Regulation 1107/2009 (Annex II, 3.8.3.) states (1):

An
active substance, safener or synergist shall be approved only if it is
established following an appropriate risk assessment on the basis of Community
or internationally agreed test guidelines, that the use under the proposed
conditions of use of plant protection products containing this active
substance, safener or synergist: will result in a negligible exposure of honey
bees, or has no unacceptable acute or chronic effects on colony survival and
development, taking into account effects on honey bee larvae and honey bee
behaviour.”

It is
clear from EFSA investigations that at least 3 neonicotinoids (imidacloprid,
clothianidin and thiamethoxam) should not have been authorised and are
currently on the market illegally. EU states must surely withdraw them from sale
pending submission of a full and complete assessment dossier. It should be noted that honey bees are one of
a myriad species, selected to represent not only pollinators but also
non-target invertebrates, regardless of whether or not they visit
flowering crops.

2. The
UK government has advocated the need to wait for its own field studies, and this
data has now been entered onto the UK DEFRA website (Thompson et al (2)). This flawed study provides no justification
whatsoever to delay a ban. The study had
no control, statistical information were omitted from public scrutiny, it has
not been peer reviewed and has been heavily criticized by independent
scientists(3). Furthermore, it is
inconsistent with findings of the UK Environmental Audit Committee inquiry,
published earlier this year(4).

3. Given
the initial interrogation of the Risk Assessment standards by EFSA in May 2012
(5), it is clear that regulatory tests were inadequate for assessing systemic
insecticides. In light of this, I ask
that (in addition to the impending EFSA assessment of Fipronil), the remaining
neonicotinoids be assessed with urgency and to at least the same standard and
independence, and that neonicotinoids and systemic insecticides with
authorisations impending, be immediately delayed until EFSA can be
certain that they meet completely the requirements of the law.

4. Millions
of EU citizens have repeatedly expressed their support for a ban on
neonicotinoids. No government or
corporation should be above the law, nor the rights and wishes of the citizens,
including those enshrined in the Aarhus
Convention, which: “links environmental rights and human rights. It
acknowledges that we owe an obligation to future generations. It establishes
that sustainable development can be achieved only through the involvement of
all stakeholders. It links government accountability and environmental
protection” (6).

Again, I wish to emphasize that
I fully support your actions to protect pollinators, and to encourage you to
exert full pressure on Member States to uphold the law. The restrictions proposed thus far, are more
than a generous compromise that favours corporation far more than pollinators,
the environment and citizens, for allowing some continued use of a poison that
has no legal right to be on the market, and for which no evidence-based
justification can be found.